Take the Stress Out of Food Recalls

Take the Stress Out of Take the Stress Out of Food RecallsFood Recalls

Jeannie Sneed, PhD, RDJeannie Sneed, PhD, RDFood Safety SpecialistFood Safety Specialist

Office of Emergency Management and Food SafetyOffice of Emergency Management and Food SafetyUSDA Food and Nutrition ServiceUSDA Food and Nutrition Service

State Agency MeetingState Agency MeetingDecember 2009December 2009

FNS Food Safety StaffFNS Food Safety Staff 22



Presentation ObjectivesPresentation Objectives

Mission of Food Safety StaffMission of Food Safety Staff

Holds and recalls processHolds and recalls process


Mission of FSSMission of FSS

Increase awareness, visibility, and impact Increase awareness, visibility, and impact of food safety on USDA nutrition of food safety on USDA nutrition assistance programs and represent FNS assistance programs and represent FNS programs in the wider Federal and State programs in the wider Federal and State food safety community.food safety community.

FSS ProjectsFSS Projects

Cooling StudyCooling Study

NorovirusNorovirus

Produce SafetyProduce Safety

Food AllergiesFood Allergies

Inventory TrackingInventory Tracking

Recall CommunicationsRecall Communications

Food DefenseFood Defense

Food Safe Schools Action GuideFood Safe Schools Action GuideFNS Food Safety StaffFNS Food Safety Staff 66


Holds and RecallsHolds and Recalls


Regulatory AgenciesRegulatory Agencies

Food Safety and Inspection Service, Food Safety and Inspection Service, USDAUSDARegulates meat, poultry, and egg productsRegulates meat, poultry, and egg products

Food and Drug Administration, HHSFood and Drug Administration, HHSRegulates all other foodsRegulates all other foods

Dual JurisdictionDual Jurisdiction


Purchasing AgenciesPurchasing Agencies

Agricultural Marketing Agricultural Marketing Service (AMS)Service (AMS)–– Egg productsEgg products–– Fruit, vegetables, nuts, Fruit, vegetables, nuts,

and specialty itemsand specialty items–– PorkPork–– BeefBeef–– Other red meatOther red meat–– PoultryPoultry–– FishFish–– Corn syrupCorn syrup

Farm Service Agency Farm Service Agency (FSA)(FSA)–– GrainGrain–– RiceRice–– Pulses (legumes)Pulses (legumes)–– Peanuts/peanut butterPeanuts/peanut butter–– Sugar and flourSugar and flour–– Dairy productsDairy products–– Vegetable oilVegetable oil–– CerealCereal–– CrackersCrackers


Types of RecallsTypes of Recalls

RegulatoryRegulatory–– VoluntaryVoluntary

–– Three classes of recallsThree classes of recalls

AdministrativeAdministrative–– Not meeting specificationsNot meeting specifications


Classes of RecallsClasses of RecallsClass IClass I A health hazard situation where there is a A health hazard situation where there is a

reasonable probabilityreasonable probability that the use of the that the use of the product will cause serious, adverse health product will cause serious, adverse health consequences or death. consequences or death.

Class IIClass II A health hazard situation where there is a A health hazard situation where there is a remote probabilityremote probability of adverse health of adverse health consequences from the use of the product. consequences from the use of the product.

Class IIIClass III A situation where the use of the product A situation where the use of the product will not will not causecause adverse health consequences. adverse health consequences.


Peanut Corporation of AmericaPeanut Corporation of America

Class I recallClass I recall——serious health serious health consequences or deathconsequences or death


Hallmark/WestlandHallmark/Westland

Class II recallClass II recall——remote probability of remote probability of health hazardhealth hazard


Recalls are VoluntaryRecalls are VoluntaryViolation foundViolation found–– Microbiological, chemicalMicrobiological, chemical

–– Statutory violations, mislabelingStatutory violations, mislabeling

Regulatory agency presents data to vendorRegulatory agency presents data to vendor

Vendor voluntarily complies with recall Vendor voluntarily complies with recall requestrequest

Vendor conducts recallVendor conducts recall–– Notifies consignees = distribution chainNotifies consignees = distribution chain

–– Issues press releaseIssues press release


FSIS/FDA RecallFSIS/FDA RecallFSIS/FDA and FSIS/FDA and ManufacturerManufacturer

ManufacturerManufacturer

FSIS/FDA and vendor discuss voluntary recall

Vendor begins to notify further processors and other customers

FSIS/FDA FSIS/FDA Press Press

ReleaseRelease

ConsigneesConsignees

Begins recall


FNS Recall EventsFNS Recall EventsFSIS/FDA FSIS/FDA

Public NoticePublic Notice

FNS AMS/FSA

NOT USDA Commodity USDA

CommodityNo ECOS (RAS) Notice

Post to ECOS Home Page


FNS Recall EventsFNS Recall EventsUSDA CommodityUSDA Commodity

DestinationsDestinations

States InformStates Inform

Further Further ProcessorsProcessors

Recipient Recipient AgenciesAgencies

(AMS/FSA provides to FNS)

(FNS notifies SDAs)

FNS loses visibility

Bulk Product to Further Processor

AMS/FSA Notifies further processors


Teamwork/CommunicationTeamwork/Communication

Industry

Purchasing Agency

RegulatoryAgency

FNS

RegionalOffices

State Distributing

Agency

RecipientAgency


Regional OfficeRegional Office

Initial recall broadcastInitial recall broadcast

Destruction informationDestruction information

Assist states in entering ECOS informationAssist states in entering ECOS information

Review and submit voucher claimsReview and submit voucher claims


Report BackReport Back

USDA USDA

State Distributing AgencyState Distributing Agency

Further Further ProcessorsProcessors

Recipient Recipient AgenciesAgencies


SDA Recall Recipient ListsSDA Recall Recipient Lists

MinnesotaMinnesota

http://education.state.mn.us/MDE/Learninghttp://education.state.mn.us/MDE/Learning_Support/FNS/Food_Distribution_Program/_Support/FNS/Food_Distribution_Program/Food_Safety/index.htmlFood_Safety/index.html

CaliforniaCalifornia

http://www.cde.ca.gov/ls/nu/fd/iapeanut.asphttp://www.cde.ca.gov/ls/nu/fd/iapeanut.asp




Standard GuidanceStandard Guidance

FNS Regulations:FNS Regulations:7CFR Part 2507CFR Part 250Section 250.13 through 250.30 containSection 250.13 through 250.30 containrequirements related to food safetyrequirements related to food safety

Hold and Recall Document, 2001Hold and Recall Document, 2001http://www.fns.usda.gov/FDD/foodsafety/holhttp://www.fns.usda.gov/FDD/foodsafety/hol

dd--recallpros.pdfrecallpros.pdf


State and Local ResponsibilitiesState and Local Responsibilities

7CFR Part 2507CFR Part 250–– Defines State Agency and/or local agency Defines State Agency and/or local agency

requirementsrequirements

–– Locals must comply with USDA and/or State Locals must comply with USDA and/or State directiondirection


Traceability is CrucialTraceability is Crucial

Know:Know:what is in inventorywhat is in inventory

where it is stored where it is stored

to whom product was sentto whom product was sent

who pickedwho picked--up productup product

Source: 7CFR 250.14Source: 7CFR 250.14


Warehousing, Distributing, and Warehousing, Distributing, and Storing Commodity FoodsStoring Commodity Foods

States are required to physically separate States are required to physically separate commodities from other inventorycommodities from other inventory

Schools are allowed to use single Schools are allowed to use single inventory, if the SDA permitsinventory, if the SDA permits



Storage FacilitiesStorage Facilities

State owned or contracted storage facilities State owned or contracted storage facilities must:must:

Identify donated foodIdentify donated foodConduct annual reviews of facilities and Conduct annual reviews of facilities and document compliancedocument complianceDocument to whom commodities were Document to whom commodities were distributed distributed Identify who pickedIdentify who picked--up up



Records are KeyRecords are KeyEveryone (SDA, Further Processor, RA) must:Everyone (SDA, Further Processor, RA) must:

–– Record what they receivedRecord what they received–– Know what they distributed and to whomKnow what they distributed and to whom

Must keep records on:Must keep records on:��DistributionDistribution��DisposalDisposal��StorageStorage��InventoryInventory��Commingling (further processors)Commingling (further processors)



2001 Commodity Hold and Recall Process2001 Commodity Hold and Recall Process

Federal responsibilities:Federal responsibilities:

HoldHold –– 10 day clock starts for investigation10 day clock starts for investigation

RecallRecall

–– FNS notifies SDAs within 24 hours of recallFNS notifies SDAs within 24 hours of recall

–– FNS provides recall notification, press FNS provides recall notification, press release, other information about tracing release, other information about tracing product and documenting reimbursementproduct and documenting reimbursement

Source: USDA/FNS GuidanceSource: USDA/FNS Guidance


2001 Commodity Hold and Recall Process2001 Commodity Hold and Recall ProcessSDA responsibilities:SDA responsibilities:

–– Assign a State Food Safety CoordinatorAssign a State Food Safety Coordinator

–– Compile similar list for RAsCompile similar list for RAs

–– Contact RAs with hold or recall notification within 24 Contact RAs with hold or recall notification within 24 hours or as soon as possiblehours or as soon as possible

–– Contact distributors/warehouses and determine:Contact distributors/warehouses and determine:

Amount of product still in storage at State levelAmount of product still in storage at State level

Amount and location delivered to RAsAmount and location delivered to RAs

–– Compile and provide to FNS:Compile and provide to FNS:

Amount and location of product still in storage Amount and location of product still in storage

Amount of product consumedAmount of product consumed

Documentation for reimbursable costsDocumentation for reimbursable costs

ource: USDA/FNS Guidanceource: USDA/FNS Guidance


2001 Commodity Hold and Recall Process2001 Commodity Hold and Recall Process

RA responsibilities:RA responsibilities:

–– Assign a Food Safety CoordinatorAssign a Food Safety Coordinator–– RAs contact sites with hold or recall notification RAs contact sites with hold or recall notification

immediately and ask that product be isolated and immediately and ask that product be isolated and inventory takeninventory taken

–– RAs provide to State:RAs provide to State:Amount and location of product still in storage Amount and location of product still in storage Amount of product consumedAmount of product consumedDocumentation for reimbursable costsDocumentation for reimbursable costs

Source: USDA/FNS GuidanceSource: USDA/FNS Guidance


ECOS/ Rapid Alert SystemECOS/ Rapid Alert System


ECOS RAS Hold/Recall ECOS RAS Hold/Recall ProcessProcess

ECOS case created when hold/recall ECOS case created when hold/recall declareddeclared

Recall contacts acknowledge receipt of Recall contacts acknowledge receipt of notification and check ECOS for detailsnotification and check ECOS for details

FNS monitors ECOS to ensure all Agencies FNS monitors ECOS to ensure all Agencies are aware of hold/recall are aware of hold/recall

ECOS allows only SDA Recall Contact to ECOS allows only SDA Recall Contact to provide product quantity and disposition provide product quantity and disposition informationinformation


Hold & Recall CoordinationHold & Recall Coordination

State AgenciesState Agencies–– Monitor ECOS for DO information & instructionsMonitor ECOS for DO information & instructions

–– Coordinate RA and Industry partner effortsCoordinate RA and Industry partner effortsProduct destruction, reProduct destruction, re--donation or returndonation or return

–– Collect and compile case information to enter Collect and compile case information to enter into ECOS case fileinto ECOS case file

Product quantitiesProduct quantities

Illness or injury informationIllness or injury information

–– Manage financial aspects of hold / recallManage financial aspects of hold / recall



Processors & Distributors:Processors & Distributors:–– Locate and sequester product in possessionLocate and sequester product in possession

–– Provide information to State Provide information to State

Identify Recipient Agencies who received Identify Recipient Agencies who received productproduct

Quantities of product sequestered, Quantities of product sequestered, delivered or unaccounted fordelivered or unaccounted for

–– Dispose of product as directedDispose of product as directed



Recipient Agencies:Recipient Agencies:–– Locate and sequester product in possessionLocate and sequester product in possession

–– Provide information to State on Provide information to State on quantities of product sequestered, delivered or unaccounted for

–– Dispose of product as directedDispose of product as directed

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Ideas for ImprovementIdeas for Improvement

Revise and update the 2001 Revise and update the 2001 ““Hold and Recall Hold and Recall ProceduresProcedures””

Train on hold and recall procedures Train on hold and recall procedures –– new new employee training a employee training a ““mustmust””

Train on inventory managementTrain on inventory management

Resolve issues with further processed productsResolve issues with further processed products

Communication strategies Communication strategies –– With other organizations With other organizations –– information multipliers information multipliers

–– Notification of hold/recall event to nonNotification of hold/recall event to non--ECOS usersECOS users

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Responding to a Food RecallResponding to a Food RecallUnder Revision!!Under Revision!!

•• Resource for foodservice Resource for foodservice

directors and managers.directors and managers.

•• Contains a checklist with Contains a checklist with

procedures for responding procedures for responding

to a food recall.to a food recall.

From NFSMIFrom NFSMI

http://www.nfsmi.org/Informatihttp://www.nfsmi.org/Information/recallmanual.pdfon/recallmanual.pdf


ResourcesResources

FNS Food Safety web pageFNS Food Safety web pagehttp://www.fns.usda.gov/fns/food_safety.htmhttp://www.fns.usda.gov/fns/food_safety.htm

Sign up for public notification: USDA/FNS Commodity Sign up for public notification: USDA/FNS Commodity

Alert SystemAlert System

National Food Service Management National Food Service Management

InstituteInstitute www.nfsmi.org www.nfsmi.org free food safety training free food safety training –– just ask!just ask!



Thanks!Thanks!

Questions?Questions?

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Take the Stress Out of Food Recalls